FAA: Altering Main Canopies

[tdog 0]

Question... In conversation with some other riggers/skydivers the following came up...

This question is for riggers and/or people that know the regulations and can cite their source.

I previously thought that the main canopy was not regulated in any way, meaning everything above the 3rings or risers, depending on how you interpret that part of the regulation, could be completely modified, altered, manufactured, adjusted, repaired, or designed by anyone.

If I wanted to jump a bed sheet on four strings, I could... If I wanted to cut off one cell and make it an 8 cell canopy that only did right hand turns, I could. We all know swoopers heavily modify their sliders, and CrEW dogs are known to make mods too... It is standard practice to tweak your main. Heck, I know of a main that was completely remade when it was damaged heavily - like complete cells added - by an owner's friend who did not have a master rigger's rating.

The other party argues that only a master rigger may alter a main canopy, and that the regulations simply allow a senior rigger or the user to alter packing techniques.

So... This question is not about what is done in the field, we all know skydivers "participate" in the maintenance of their main...

But, the actual regulations...

Scenarios:

1) A friend without a rating alters a friends main canopy, per the owners request.

2) The owner alters his own main canopy.

3) A friend, who happens to be a senior rigger, alters a friends main canopy, per the owner's request.

[diablopilot 2]

Oh boy, here we go again....I have to go dig up some files, but the gist of my interpretation of the FAR's suggest that without a rigging certification a person may do just about anything they wish to their own main, but a senior rigger cannot do work to a main.

The argument can be made that a senior rigger may not do any patch work or line replacement, but I'm pretty sure this is absolutely NOT the intensions of the FAR's and is simply a mistake in wording since the latest revision.

Edit: Oh and I'll take a guess who your source is, he's a guy I like and respect quite a bit, but we don't see eye to eye on this one.

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You're not as good as you think you are. Seriously.

[masterrigger1 2]

JP,
I am going to post this....against my better judgement.


I just saw the removal of the word "alter" in 65.111.

Washington removed that as of this past Monday.It is going through legal as we speak.

We have a new overall manager at Washington with regards to Parachuting.

AC1052C is being re-written also to clear up some of the confusion.


The simple fact is this:

Major repairs, alterations, and modifications can only be done by a Master rigger.


The difference is that the certificated ones require approval from either the manufacturer or the FAA..

Non-certificated ones do not.

I simply do not have the time to debate this any longer.

I am trying to find a new full time job and this will definitely pull me away from that effort.......


Cheers,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[diablopilot 2]

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Subpart F—Parachute Riggers

§ 65.111 Certificate required.

(a) No person may pack, maintain, or alter any personnel-carrying parachute intended for emergency use in connection with civil aircraft of the United States (including the reserve parachute of a dual parachute system to be used for intentional parachute jumping) unless that person holds an appropriate current certificate and type rating issued under this subpart and complies with §§65.127 through 65.133.

(b) No person may pack, maintain, or alter any main parachute of a dual-parachute system to be used for intentional parachute jumping in connection with civil aircraft of the United States unless that person—

(1) Has an appropriate current certificate issued under this subpart;

(2) Is under the supervision of a current certificated parachute rigger;

(3) Is the person making the next parachute jump with that parachute in accordance with §105.43(a) of this chapter; or

(4) Is the parachutist in command making the next parachute jump with that parachute in a tandem parachute operation conducted under §105.45(b)(1) of this chapter.

And on an unrelated note, with the following in mind how many riggers do you know that are working outside the limitations of their certificate.

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No certificated parachute rigger may exercise the privileges of his certificate unless he has at least the following facilities and equipment available to him:

(a) A smooth top table at least three feet wide by 40 feet long.

(b) Suitable housing that is adequately heated, lighted, and ventilated for drying and airing parachutes.

(c) Enough packing tools and other equipment to pack and maintain the types of parachutes that he services.

(d) Adequate housing facilities to perform his duties and to protect his tools and equipment.

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You're not as good as you think you are. Seriously.

[diablopilot 2]

If that new FAA manager did approve the removal of the word "alter" then they did the skydiving community a huge disservice. Who was consulted? How much experience does the manager have with skydiving?

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You're not as good as you think you are. Seriously.

[tdog 0]

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The simle fact is this:

Major repairs, alterations, and modifications can only be done by a Master rigger.

I know you don't want to argue this on the net, so please don't feel like you need to reply.

However, if true, that is too bad...

For an example, Brian Germain has a senior rigger's rating accoring to his DZ.com profile, but he has done some pretty incredible canopy design and repair work in his day. Does he have to now hire a master rigger in his shop to sew his newest prototype canopy or fix a canopy sent in for repair?

What about changing brake line lengths for a friend who discovers with a canopy coach their main is not appropriately dialed in... I used to help friends do that all the time when I had no rating. Now that I am a senior rigger I can't? The owner can't? Or changing the slider or lineset materials on a canopy for softer openings? Or having a removable slider? Or making your own lineset? I know there is a fine line between minor repair (what a senior rigger can do) and an alteration.

Laws should always reflect accepted industry standard practice, and I don't think I can find many fatalities or injuries to suggest users and or senior riggers "altering" canopies to be a safety issue.

By making laws that contradict standard practice, it places liability on everyone involved.

I believe it was mentioned that a revision to part 65.111 was being made? What is the wording in that revision?

[riggerrob 558]

Tdog,

You really need to go re-read the limits of Senior Rigger Certificates as defined in the FARs.

For example, it is perfectly legal for a Senior Rigger to replace a factory-supplied slider. Since even Performance Designs admits that sliders were too small on early Sabre 1 canopies, a Senior Rigger can legally ASSEMBLE A CANOPY IN ACCORDANCE WITH THE MANUFACTURER'S INSTRUCTIONS.

On the other hand, Senior Riggers making line sets is clearly in defiance of FARs because they define the replacement of one line as a MAJOR REPAIR, the exclusive perview of Master Riggers.
The only other person who can - legally - replace a line is the factory and that needs the blessing of a TSO inspector before it goes back into service.

As for factories needing to hire Master Riggers to do repairs ... Tee! Hee!
As long as the repair passes TSO inspectors, it does not matter who dd it.
For example, when I started working at Rigging Innovations, I only held an FAA Senior Rigger rating, but soon found myself retro-fitting Cypres pockets, replacing side flaps and re-sizing harnesses. That was legal because all my work was inspected (IAW TSO standards) before it left the factory. Even after I earned a Master Rigger rating, I still had to march all my repairs past a TSO inspector.

It is too easy for this debate to deteriorate into a scene from Monty Python, because - in practice - only Master Riggers or factories have the tools, materials and skills to do major repairs.

[riggerrob 558]

"... but a senior rigger cannot do work to a main.

The argument can be made that a senior rigger may not do any patch work or line replacement, ..."

>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>

Go read the FARs.

Senior Riggers are allowed to do MINOR REPAIRS to main canopies. In practice, this is limited to sewn patches (8 or 9 inches?) in the middle of panels. If a patch includes a seam or suspension line, then it needs to be done by a Master Rigger.

[diablopilot 2]

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For an example, Brian Germain has a senior rigger's rating accoring to his DZ.com profile, but he has done some pretty incredible canopy design and repair work in his day. Does he have to now hire a master rigger in his shop to sew his newest prototype canopy or fix a canopy sent in for repair?

Ready for a laugh?

A Manufacturer does not have to have any certifications! Simply a TSO if it's a TSO's component.

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You're not as good as you think you are. Seriously.

[diablopilot 2]

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It is too easy for this debate to deteriorate into a scene from Monty Python, because - in practice - only Master Riggers or factories have the tools, materials and skills to do major repairs.

Wanna bet?

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You're not as good as you think you are. Seriously.

[riggerrob 558]

"(a) A smooth top table at least three feet wide by 40 feet long."

>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>

That regulation was dropped 1993, when US President Bill Clinton de-regulated parachute lofts.
IOW the FAA quit inspecting and certifying parachute lofts.
While those large tables may be mandatory for packing round canopies, they are only "convenient" when working on squares.
Remember that sales of round reserves collapsed in the late 1980s after the whole acid mesh scandal.
With round canopies rapidly disappearing from the skydiving scene, the FAA quietly dropped standards relating to packing round parachutes.

>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>

Again, go read a RECENT copy of the FARs.

[riggerrob 558]

"What about changing brake line lengths for a friend who discovers with a canopy coach their main is not appropriately dialed in... I used to help friends do that all the time when I had no rating. Now that I am a senior rigger I can't? "

>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>

If he is installing toggles at the length recommended by the factory, A Senior Rigger is operating within the limits of his certificate.

Hint: most skydivers will tie their steering lines way too short, or uneven, if you let them.

You guys really need to go read the latest version of the FARs.

[tdog 0]

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You really need to go re-read the limits of Senior Rigger Certificates as defined in the FARs.

I have read them. I am pointing out that they are conflicting to "standard industry practice." I intentionally left this open so it could be debated.

I pointed out a lot of this as devils advocate because most skydivers in PRACTICE are not following the rules, and thus - should the rules be changing (as apparently they are being revised) to further clarify how many people truly are breaking the rules??? Maybe the rule needs to be clarified to allow what is standard practice in the field?

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As long as the repair passes TSO inspectors, it does not matter who dd it.

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The only other person who can - legally - replace a line is the factory and that needs the blessing of a TSO inspector before it goes back into service.

For an example, without a master rating, can someone like Brian Germain put a lineset on his own canopy that he may or may not sell or loan to others??? He has. Does he have a TSO inspector since his main is not TSO approved???? Maybe he does, I don't know? Mains are not "approved parachutes". No TSO stamp on mine...

But in practice, I know many people without any rating who made new linesets or did major repairs to their linesets (like replace a large quantity of lines).

[diablopilot 2]

Quote

"(a) A smooth top table at least three feet wide by 40 feet long."

>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>

That regulation was dropped 1993, when US President Bill Clinton de-regulated parachute lofts.
IOW the FAA quit inspecting and certifying parachute lofts.
While those large tables may be mandatory for packing round canopies, they are only "convenient" when working on squares.
Remember that sales of round reserves collapsed in the late 1980s after the whole acid mesh scandal.
With round canopies rapidly disappearing from the skydiving scene, the FAA quietly dropped standards relating to packing round parachutes.

>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>

Again, go read a RECENT copy of the FARs.

I did. The most current version, directly from www.faa.gov

The point is, I know that the requirement is silly, as does everyone else in the field. But if we follow the "letter of the law", hell we'd pretty much never get off the ground.

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You're not as good as you think you are. Seriously.

[Andrewwhyte 1]

If a repair is made to a certificated part it is recorded on the packing card. Since the main is field interchangeable there will be no documentation for the alteration. It seems like a completely unenforceable regulation; when the FAA guy asks who altered the dead guy's main he wont get an answer.

[livnbored 0]

heehee.
I remember what Dave DeWolfe said.

It went something like this...

... Anyone can build a main parachute. However, if something breaks on it they either have to be a rigger to fix it, hire a rigger to fix it or just build themselves a whole new parachute.

[Andrewwhyte 1]

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heehee.
I remember what Dave DeWolfe said.

It went something like this...

... Anyone can build a main parachute. However, if something breaks on it they either have to be a rigger to fix it, hire a rigger to fix it or just build themselves a whole new parachute.

Hi, we're from the FAA. We're here to help.

[tdog 0]

That is VERY funny.

Sad but true.

Maybe we can get it changed so the rules follow accepted practice in the field, as skydivers are not dieing due to fixing or repairing their mains, and there are not enough master riggers to replace every broken line out there when skydivers can't fix their own. :-) (if true)

[Samurai136 0]

Quote

heehee.
I remember what Dave DeWolfe said.

It went something like this...

... Anyone can build a main parachute. However, if something breaks on it they either have to be a rigger to fix it, hire a rigger to fix it or just build themselves a whole new parachute.

"No,sir. I'm not repairing or altering my main parachute... I just never finished building it."

"Buttons aren't toys." - Trillian
Ken

[deadwood 0]

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If a repair is made to a certificated part it is recorded on the packing card. Since the main is field interchangeable there will be no documentation for the alteration. It seems like a completely unenforceable regulation; when the FAA guy asks who altered the dead guy's main he wont get an answer.

Though its not a bad idea, it's not required by the regulations to log a repair on the packing data card. The proper place to record it is in you log book.

However, you are required to log any defects found during your inspection on the packing data card.

One more question: Is anal retentive supposed to be hyphenate?

He who hesitates shall inherit the earth.

Deadwood
Skydive New Mexico Motorcycle Club, Touring Division

[mark 103]

Quote

Quote

"(a) A smooth top table at least three feet wide by 40 feet long."

>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>

That regulation was dropped 1993, when US President Bill Clinton de-regulated parachute lofts.
IOW the FAA quit inspecting and certifying parachute lofts.
While those large tables may be mandatory for packing round canopies, they are only "convenient" when working on squares.
Remember that sales of round reserves collapsed in the late 1980s after the whole acid mesh scandal.
With round canopies rapidly disappearing from the skydiving scene, the FAA quietly dropped standards relating to packing round parachutes.

>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>

Again, go read a RECENT copy of the FARs.

I did. The most current version, directly from www.faa.gov

The point is, I know that the requirement is silly, as does everyone else in the field. But if we follow the "letter of the law", hell we'd pretty much never get off the ground.

Good news! The table is required, the height of the table can be zero. When I got my seat rating in Nashville (before 1993), I secured the apex behind the toilet, ran the parachute out the bathroom door, across the family room, through the service door into the garage, and secured the harness to the tension board under the garage work bench. The FAA thought that was just fine.

More good news! You have to have access to the table, but you're not required to use it. So long as you could have used it if you needed to, that's enough.

Mark

[parachutist 1]

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On the other hand, Senior Riggers making line sets is clearly in defiance of FARs because they define the replacement of one line as a MAJOR REPAIR, the exclusive perview of Master Riggers

Manufacturing of an entire line set would be out of bounds for a senior rigger, however I disagree about replacement of 1 line being clearly in defiance. As written in the FAA Parachute Rigger Handbook, which is published on FAA's web site and which is listed in FAA-G-8082-15C PARACHUTE RIGGER KNOWLEDGE TEST GUIDE as a study resource which is of particular interest:

Parachute Repair Procedure
TITLE: 7.1.9 Square Canopy – Main Line Replacement
NUMBER OF PAGES: 2
APPLICABLE PRODUCTS: Square main canopies.
DESCRIPTION: Replacement of main suspension lines of square canopies.
AUTHORIZED REPAIRMEN: FAA Senior or Master Parachute Rigger

[masterrigger1 2]

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Manufacturing of an entire line set would be out of bounds for a senior rigger, however I disagree about replacement of 1 line being clearly in defiance. As written in the FAA Parachute Rigger Handbook, which is published on FAA's web site and which is listed in FAA-G-8082-15C PARACHUTE RIGGER KNOWLEDGE TEST GUIDE as a study resource which is of particular interest:

Parachute Repair Procedure
TITLE: 7.1.9 Square Canopy – Main Line Replacement
NUMBER OF PAGES: 2
APPLICABLE PRODUCTS: Square main canopies.
DESCRIPTION: Replacement of main suspension lines of square canopies.
AUTHORIZED REPAIRMEN: FAA Senior or Master Parachute Rigger

That is just one of many mistakes in that book that is currntly being evaluated and corrected.

As always, the FAR's are law. The book is just a reference and on this issue a very bad one at that.


Cheers,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[mark 103]

Quote

Quote

Parachute Repair Procedure
TITLE: 7.1.9 Square Canopy – Main Line Replacement
...
DESCRIPTION: Replacement of main suspension lines of square canopies.
AUTHORIZED REPAIRMEN: FAA Senior or Master Parachute Rigger

That is just one of many mistakes in that book that is currently being evaluated and corrected.

As always, the FAR's are law. The book is just a reference and on this issue a very bad one at that.


Cheers,
MEL

Here's a previous reference:

Poynter Volume 2
7.26 Line replacement in ram-air canopies
A. Comment ...
B. Applicable Canopies ...
C. Repair Personnel
Non-certificated canopy: Senior or Master Parachute Rigger
Certificated canopy: Master Parachute Rigger

Because the standards for airworthiness are different for reserves and mains, it is entirely appropriate that only master riggers might be permitted to work on one, but senior riggers might be permitted to work on the other.

Poynter Volume 2 was published in 1991, so the industry standard for more than 16 years has been to allow senior riggers to work on lines. The FAA has had plenty of time to object and has not.

The way we need to read AC 105-2C's example of fixing a broken line as a major repair is that it is a major repair if done for a reserve.

Still not convinced?

Poynter Volume 1 -- yes, the original -- says that replacement of a line is a senior rigger privilege if done to a main. Volume 1 predates the current AC 105-2C by a few years.

Yes, the FARs are law, but they don't specify particular repairs as major repairs. AC-1052C is an Advisory Circular, so it is not law. It gives us guidance and insight into FAA thinking. If it is possible to read Poynter and interpret AC 105-2C without conflict, we should do so.

Mark

[masterrigger1 2]

Mark,
Poynter's has errors as well, just not as many as the PRH.

That's one of them.
AC-105-2C spells out that replacing a line of a main canopy is a major repair......

To me there is no question..... there are also other references that I have used. One is a controlled item that only DPREs and FAA personel have.

Pontyer's is a reference book also with errors, just no one had the errors fixed.
In fact there are contradictions between Volume One and Two if one were to look.

***
Yes, the FARs are law, but they don't specify particular repairs as major repairs. AC-1052C is an Advisory Circular, so it is not law. It gives us guidance and insight into FAA thinking. If it is possible to read Poynter and interpret AC 105-2C without conflict, we should do so.

Quote

I asked that question several times. The answer that I have gotten is that the AC1052C is an considered a further explaination of the FARs AND could/would be used in a court of law if need be.


In fact, Sandy Reid used that same answer at the PIA.

When questioned about the FAR/AC-105-2C differences regarding the TSO compatibility deal, that was almost his exact answer.

So, If it can be used for one reference, it can be used for others.

There is conflict between AC-105-2C and Poynters, so you can not avoid it.

One last question is this:
Which one takes precidence over the other; AC-105-2C or a reference book.

Of course, it would be the AC over a reference book.


Cheers,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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